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v. Commissioner, supra at 1019-1021, we described these
approaches as follows:
There are various approaches which may be
taken in establishing whether a purchaser may
treat a nonrecourse liability as a bona fide
debt. One, originating in Estate of Franklin
v. Commissioner, 544 F.2d 1045 (9th Cir. 1976),
affg. 64 T.C. 752 (1975), indicates that when
the amount of the aggregate purchase price
unreasonably exceeds the value of the property
securing the note (or when the principal amount
of the note unreasonably exceeds the value of
the property securing the note), the debt will
not be recognized. In such instance, the
purchaser acquires no equity in the property
by making payments and, therefore, would have
no economic incentive to pay off the note.
Estate of Franklin v. Commissioner, supra at
1048-1049. The Estate of Franklin analysis,
comparing the purchase price and size of the
note to the fair market value of the property
at the time of purchase, originated in real
estate transactions (see Estate of Franklin v.
Commissioner, supra; Narver v. Commissioner,
75 T.C. 53 (1980), affd. per curiam 670 F.2d
855 (9th Cir. 1982); Beck v. Commissioner, 74
T.C. 1534 (1980), affd. 678 F.2d 818 (9th Cir.
1982)), but has also been applied to the
purchase of cattle (see Hager v. Commissioner,
supra), and, more recently, to movies (see
Wildman v. Commissioner, supra; Siegel v.
Commissioner, supra; Brannen v. Commissioner,
supra).
Another line of cases, in many ways compli-
mentary to the above, more closely addresses
the problem of bona fide loans where the sole
security for such loans is a speculative asset
with an undeterminable value at the time of
purchase. This line of decisions holds that
highly contingent or speculative obligations
are not recognized for tax purposes until the
uncertainty surrounding them is resolved. CRC
Corp. v. Commissioner, 693 F.2d 281 (3d Cir.
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